E-Scooter and LEV Fleets: Do the Battery Passport Rules Apply to You?

If you run a shared e-scooter service, a delivery fleet or any operation with light electric vehicles on the road, the battery passport probably feels like someone else's problem. You are not selling batteries, you are running them. That instinct is right in one case and wrong in another, and the difference comes down to how the batteries reach your fleet.

The rule that catches fleets

The passport requirement applies to LMT batteries, industrial batteries over 2 kWh and electric vehicle batteries that are placed on the market or put into service from 18 February 2027 (Art. 77(1) of Regulation (EU) 2023/1542).

That second phrase is the one fleet operators miss. The obligation is not limited to selling. Putting a battery into service is enough to bring it into scope, so importing scooters or packs from outside the EU for your own operation does not sidestep the requirement simply because nothing is sold on.

Two situations, two different answers

Work out which of these you are:

You import the vehicles or batteries yourself. You buy directly from a manufacturer outside the EU and bring them in. Here you are the importer and the economic operator, and the passport duty is yours, exactly as it would be for a retailer. See who is responsible for the battery passport. You will also carry the other importer checks: conformity documentation, CE marking, labelling, and putting your own name and address on the battery (Art. 41).

You buy from an EU supplier. You purchase from a distributor or manufacturer already established in the EU. Here you are not the one placing the battery on the EU market, so the passport should already exist, produced by whoever did. Your job shifts from producing passports to checking that they exist and work.

Fleets frequently do both, often without noticing: vehicles bought through an EU distributor, replacement packs ordered directly from the factory to save cost. The second route quietly makes you an importer.

Every battery in an LMT fleet is in scope

There is no capacity threshold for LMT batteries, so a small scooter pack counts the same as a large cargo-bike pack. See battery passport requirements for LMT batteries. For a fleet, that means:

• The packs in the vehicles as delivered.
• Spare and replacement packs, which are batteries in their own right.
• Packs bought mid-life to keep older vehicles running, if you are the one bringing them into the EU.

Fleets churn batteries faster than retail does, because packs are cycled hard and swapped often. That makes the replacement channel the one to look at first.

What to do if you buy inside the EU

Your work is verification rather than production, and it is worth doing before February 2027 rather than after:

1. Ask your supplier now whether passports will exist for the models you run, and how you will reach them.
2. Check the data carrier is on the pack. From 18 February 2027 the QR code has to be there (Art. 13(6)).
3. Write it into your purchase terms for future orders, so a supplier that cannot deliver a passport is a problem you find at contracting rather than at delivery.
4. Keep your own records of which models you run and where their passports live.

What to do if you import

Treat yourself as an importer and run the full process: confirm scope per model with the scope checker, collect the Annex XIII data from the manufacturer, and plan hosting. See what your supplier must send you, and passport data you can declare yourself vs data only your supplier has for how to split the work.

The long tail: batteries stay in service

One point specific to fleets. The passport has to remain accurate and available while the battery is in service, and fleet packs often stay in use for years and are later sold on, refurbished or retired. Whatever you build has to survive that, including for vehicles you no longer own. See how long a battery passport must stay online.

In short

Fleets are not automatically outside the rules. The passport applies to batteries placed on the market or put into service, so importing for your own operation counts. If you buy from an EU supplier, your job is to verify that passports exist and are reachable; if you import directly, including replacement packs, the duty is yours. Check the replacement channel first, because that is where most fleets become importers without realising it.